This month's newsletter features articles about the agreement between Switzerland and the United States to permit some Swiss banks to participate in a settlement program and avoid criminal prosecution over accounts maintained by US taxpayers; the First Circuit's decision in Sun Capital, in which the First Circuit found that a private equity fund was engaged in a "trade or business" for ERISA purposes; and the Fifth Circuit's decision in Nevada Partners, affirming the trial court's decision that FOCus transactions lacked economic substance and application of the negligence penalty despite the taxpayers' reliance on outside attorneys and accountants.
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